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Monday, January 30, 2012

The January 2012 issue of Physics Today has an interesting article by Notre Dame physics professors Philippe Collon and Michael Wiescher. Titled "Accelerated Ion Beams for Art Forensics," it discusses the use of non-invasive nuclear physics to detect forged art and more. For example, the authors write about the ability of PIXE (Particle Induced X-Ray Emission) to analyze the make-up of an object:

"The scope of applications of PIXE in the art world has grown steadily. When applied to a work of art, as shown in the figure, PIXE helps to identify the composition of pigments or other materials; thus it has had a growing impact in the forensic analysis of suspected forgeries. The analysis of ancient coins provides information about the minting process and also leads to deeper insight into economic developments. For example, inflation during the Roman Empire is reflected in a continuous devaluation of the silver denarius coin, as silver was gradually replaced by less valuable metals. In collaboration with others at Notre Dame, we are investigating the unique black-and-white ceramics of the American Southwest to identify whether mineral or organic pigments have been used to generate the paint and to determine the provenance and distribution of the pottery material. We have also joined with our colleagues to explore the frequently shifting 18th-century colonial boundaries in the present US Midwest by studying the composition of regional Native American copper jewelry. With PIXE, copper mined locally in the upper lake region can be distinguished from British or French imported copper."

Read more about PIXE testing and the authors' discussion of accelerator mass spectrometry here.

Friday, January 27, 2012

The International Council of Museums (ICOM) today announced that it would soon release a Red List for Egypt. [UPDATE 2/6/12: The Red List is now available]. Red Lists describe various types of cultural objects that are considered to be at-risk. Such lists have been created for cultural objects from Afghanistan, Cambodia, Africa, and seven other places.

Regarding Egypt, ICOM's December-January e-newsletter states:

"Following several months of preparation, ICOM is delighted to announce the official launch of a new Red List in the coming weeks. TheEmergency Red List of Egyptian Cultural Objects at Risk, the 11th publication in ICOM’s Red List series and its third Emergency Red List, is one of the tangible outcomes of ICOM’s involvement in the protection of Egyptian cultural heritage, following the events that shook the country in the past year. The List was drafted in close collaboration with members of ICOM’s International Committee for Egyptology (CIPEG), national and international experts in Egyptian art and antiquities, and the Ministry of Antiquities of Egypt."

"The Emergency Red List was made possible thanks to the generous support of the Bureau of Educational and Cultural Affairs of the US Department of State."

"The official launch of the Emergency Red List of Egyptian Cultural Objects at Risk will take place at the National Museum of Egyptian Civilisation (NMEC) in Cairo, Egypt, in the presence of ICOM Director General Julien Anfruns, members of the Egyptian government and local heritage institutions, national and international experts, police and customs officials, partners of the project and the media. The event will be followed by an awareness-raising and capacity-building workshop on the Red List series and its worldwide usage in fighting illicit traffic in cultural goods."

Tuesday, January 24, 2012

Even before trial begins and testimony is heard, the case against Joseph Lewis, II must be dismissed because the government cannot prove its case. That is what defense lawyers argue in a motion filed today in the US District Court, Eastern District of New York in the case of US v. Khouli et al. The lengthy memorandum of law contends that the government lacks sufficient evidence to proceed to trial based on the information supplied in discovery materials.

Evidence in US v. Khouli et al.Source: ICE

A federal grand jury indicted Joseph Lewis, Moussa Khouli, and two others in July 2011 alleging, in part, that Lewis illicitly bought Egyptian antiquities that were illegally imported into the United States through Dubai. The indictment also alleges that the four conspired together and with unidentified “others” in a smuggling operation. (A defendant is presumed innocent unless the government proves guilt beyond a reasonable doubt). The objects involved in the case include a Greco-Roman style Egyptian sarcophagus and a three-part nesting coffin set. See here for background.

Despite being accused of wrongdoing related to the import of ancient Egyptian antiquities, defense lawyers contend that Lewis was not involved with the importation process at all. In fact, the only co-defendant Lewis had contact with at any time was Moussa Khouli, and that contact was after any object was imported into the United States, according to attorneys. This argument is buoyed by defense lawyers' statements asserting that Lewis had neither sent nor received any emails discussing importation of cultural artifacts with Khouli. Therefore, Lewis' lawyers argue that Lewis had no participation in the import process.

Lewis had every reason and motive to want the import process to be legal, the defense attorneys claim. Email exchanges between Khouli and Lewis never hinted at any illegal activity, they say. Lewis, in fact, never had any idea that any pieces were stolen, particularly after having been informed by Khouli in writing at least seven times that the Egyptian pieces were part of Khouli’s father’s collection in Israel during the 1960’s.

Moreover, defense counsel contends that prosecutors cannot prove that the items in questions were stolen. They highlight that there has been no assertion by Egypt that the items are in fact stolen. And if the prosecution argues that the incomplete provenance of the artifacts should have informed Lewis that the objects may have been stolen, defense lawyers cite journal articles to show that lack of provenance is common in the antiquities market and does not demonstrate that a cultural object is in fact stolen. Lewis’ lawyers conclude that the lack of evidence cannot sustain a conviction, warranting a dismissal of the government's criminal case.Contact: www.culturalheritagelawyer.com

Wednesday, January 18, 2012

Attorneys for the United States have filed their brief in the matter of Ancient Coin Collectors Guild v. U.S. Customs and Border Protection; U.S. Department of State; Assistant Secretary of State, Educational and Cultural Affairs. The United States’ brief rejects the Ancient Coin Collectors Guild’s (ACCG) interpretation and application of the Cultural Property Act (CPIA), writing that the ACCG “fundamentally misunderstands the CPIA’s statutory scheme.”

Last September the ACCG appealed to the Fourth Circuit Court after a federal district court judge dismissed its test case. The group initially filed the lawsuit hoping to challenge cultural heritage import protections enacted under the Cultural Property Implementation Act (CPIA). According to the government’s brief, “[o]n April 15, 2009, [the ACCG] transported [Chinese and Cypriot] coins from London to Baltimore with the intention of testing the validity of existing import restrictions. The invoice accompanying the coins identified each by type and indicated that each was minted in China or Cyprus, but provided no indication of when the coins first arrived in London (or any other information regarding the history of the coins).” Customs seized the ancient coins. The district court then struck down the ACCG’s challenge to the seizure after concluding that the group failed to make out a sufficient case to show that the government acted outside its legal authority.

The ACCG filed an appellate brief with the federal circuit court on October 31, 2011, arguing that the enactment and application of the import controls by the State Department and/or Customs and Border Protection (CPB) was unlawful and should be reviewed under the standards of the Administrative Procedures Act (APA). (The APA is the law that instructs federal agencies about how they must establish administrative regulations. The Act also outlines the procedures by which administrative decisions are reviewed by the courts.) The ACCG also argued in its brief that the United States government could not issue cultural property import protections on certain ancient coins since China allegedly did not request the import restrictions. The group further explained that the CPIA’s import controls require federal officials to prove an ancient coin’s find spot before it can be seized. The United States’appellate brief, filed on January 13, 2012, counters these claims.

Attorneys for the United States contend in their brief that its agencies followed the rules while the ACCG did not follow the process. The government's lawyers write that the ACCG should have followed the forfeiture process established by Congress. Instead, the ACCG filed a lawsuit. “The CPIA’s provisions regarding seizure and forfeiture, in concert with the pre-existing statutory scheme addressing forfeiture proceedings, set forth a process by which claimants may contest a threatened forfeiture,” the government argues. Federal lawyers state that the “APA authorizes judicial review of agency action only ‘for which there is no other adequate remedy in a court.’ The circumstances in which extra-statutory review is available are similarly limited. Here, however, Congress has expressly provided for challenges to the seizure and forfeiture of materials under the CPIA through the established mechanism of administrative or judicial forfeiture proceedings.”

At the time of the attempted import of the coins in Baltimore, lawyers for the United States say that “Customs provided [the ACCG] with the opportunity to present a certification of lawful export or other evidence establishing a right to entry . . . . [but the ACCG] disclaimed any ability to present such evidence. On July 20, 2009, Customs seized the coins, and explained that – in light of [the ACCG’s] representations – the items would be subject to summary forfeiture absent a request by plaintiff for judicial proceedings.” Government lawyers say that even though the ACCG requested a judicial forfeiture proceeding in September 2009, “Plaintiff [ACCG] did not await the commencement of judicial forfeiture proceedings by the U.S. Attorney’s Office. Rather, on February 11, 2010 – five months after requesting such proceedings – plaintiff commenced this suit to challenge the seizure of its ancient Chinese and Cypriot coins.” The government observes that “Plaintiff [ACCG] has invoked those procedures, but they have not occurred as this litigation has been ongoing. Plaintiff does not explain why its arguments should not be considered in the forum designated by Congress.”

Had the ACCG challenged the seizure of the coins through the congressionally prescribed forfeiture proceeding, it would have confronted a defined standard of proof requiring the ACCG to show that the coins were legal to import. The government’s brief describes the standard of proof that applies in a forfeiture proceeding: “the government must establish that the seized property is material that has been designated as restricted under [the CPIA]. After this initial showing, the burden shifts to the claimant [ACCG] to show that the property is not subject to forfeiture, or to establish an applicable affirmative defense.”

The United States rebukes the ACCG for short-circuiting the judicial forfeiture proceeding, avoiding its burden of proof, and claiming that the government acted beyond its authority (i.e. ultra vires). The government contends that the “Plaintiff [ACCG] cannot properly circumvent the statutory scheme established by Congress by asking a district court to review this seizure under the APA and under the rubric of ultra vires review and . . . to further confound Congress’s intent by asking the court to disregard the burden of proof established by the CPIA.”

Attorneys for the United States further maintain that the ACCG has confused the meaning and requirements of the CPIA. They point out that “[t]o import the coins into the United States, plaintiff [ACCG] needed only to show that the coins had left Cyprus or China before the effective dates of the relevant Designated Lists. Plaintiff declined to offer any declaration to that effect, claiming that it could not offer the evidence required by the statute because it did not know whether the coins had been ‘first found in the ground’ of either China or Cyprus. But the CPIA quite plainly does not require plaintiff to know where the coins were ‘first found in the ground’; all that was required was information as to the whereabouts of the Cypriot coins as of July 16, 2007 and of the Chinese coins as of January 16, 2009.”

The government's lawyers pointedly draw attention to the fact that the President exercises his foreign affairs powers when acting pursuant to the CPIA. The attorneys highlight that “[t]he provisions of the CPIA confirm that Congress recognized that these judgments are imbued with foreign policy concerns.” They describe how “[t]he CPIA provides the President with broad power to apply import restrictions pursuant to MOUs he enters into with foreign States in furtherance of the United States’s obligations under the Convention on Cultural Property and with the goal of ‘promoting U.S. leadership[] in the preservation of cultural treasures.’” The attorneys point out that “Congress recognized that allowing illicitly excavated and trafficked artifacts to enter into the United States, thereby permitting a market in such goods, threatened our relationships with other nations, and that this legislation was thus “‘important to our foreign relations.’” They also explain that “the issues raised by the import of cultural goods are ‘distinct from the normal concerns of the reciprocal trade agreements program or U.S. trade law.’”

The review of American foreign policy decisions by the courts essentially would be improper, suggests the brief, particularly where foreign policy considerations have other avenues of oversight. “Rather than involve the courts in an inquiry into the conduct of foreign affairs, Congress provided for political review by requiring the CPAC [Cultural Property Advisory Committee] to share its reports with Congress, and requiring the President to report actions taken to Congress,” says the government’s brief.

Federal lawyers contend that even if there is court review of the government’s implementation of import restrictions enacted under the CPIA, government agencies acted properly. Their brief asserts that “[i]f the Court concludes that some form of judicial review is nevertheless appropriate in these proceedings, it should affirm the district court’s conclusion that plaintiff has not stated a viable claim.”

In support of this argument, attorneys for the United States point out that the ACCG’s “primary contention is that its 22 ancient Cypriot and Chinese coins were unlawfully seized based on their ‘type.’ Plaintiff urges that, although the coins appear on the Designated Lists of restricted materials published by Customs, the coins must be allowed entry to the United States unless the government can prove, on a coin by coin basis, that each was first unearthed in Cyprus or China. The district court correctly concluded that plaintiff’s proposed scheme lacks any basis in the statute.” Therefore, the federal lawyers maintain that “[t]he Assistant Secretary [of State] exercised her judgment and discretion under the CPIA in determining that certain types of ancient Cypriot and Chinese coins qualify as the ‘archaeological material of the State Party’ and applying import restrictions to them. As the district court concluded, plaintiff’s approach can not (sic) be reconciled with the plain terms of the Act, is unworkable, and ‘would undermine the core purpose of the CPIA.’”

Attorneys for the United States also address in their brief the ACCG’s request for information. “[The ACCG’s] amended complaint alleged that ‘China never formally requested import restrictions on coins,’ and urged that the government’s restrictions on Chinese coins should thus be deemed invalid. This is unsurprising, since – as the government has previously noted – China’s request did, in fact, address ancient Chinese coins, as noted in the public summary of the request that is posted on the State Department’s website.” That said, federal lawyers declare that “the district court correctly rejected plaintiff’s request for discovery with regard to the precise contents of China’s diplomatic note requesting that the United States impose import restrictions under Article 9 of the Convention on Cultural Property. The United States has met all of its statutory obligations, and is not required to make such information public."

Finally, the government addresses the constitutional issues raised by the ACCG: “Plaintiff asserts that the import restrictions at issue 'impinge on collectors’ access to information materials' in a 'grossly overbroad' manner and are thus 'constitutionally suspect under both the First and Fifth Amendments.' Contrary to plaintiff’s characterization, the CPIA does not ban the sale of ancient coins or prevent individuals from accessing the information they offer. Rather, the [CPIA] allows the importation of the designated coins when particular requirements, which are designed to prevent the illicit trafficking of ancient artifacts that are under threat from pillage or looting, are satisfied. It is contrary to no recognized constitutional interest."

[Note: All quotes are from the government's appellate brief. Citations in the original have been omitted.]

Wednesday, January 11, 2012

An article appearing in Coin World reports that law enforcement officials on January 3, 2012 seized two ancient Greek coins from Italy before they were sold at a New York International Numismatic Convention event held in Manhattan. The article states that the owner of the coins, Dr. Arnold-Peter Weiss, was detained.

New York Criminal Court records reveal that authorities on January 3, 2012 at 2:15 p.m. arrested and charged a man named Arnold Peter C. Weiss, born 1960, with Criminal Possession of Stolen Property (CPSP) valued at over $50,000. The court set bond in the amount of $200,000 and scheduled the next court date for March 21, 2012.

As of this writing, the NY County District Attorney's Office has not released any official statement confirming that this arrest and charge are related to the coin seizures reported by Coin World. However, Chasing Aphrodite is reporting a connection.

A violation of the CPSP statue, New York Penal Law 165.52, is a class “C” felony punishable by up to a maximum of 15 years in prison. The statute states: "A person is guilty of criminal possession of stolen property in the second degree when he knowingly possesses stolen property, with intent to benefit himself or a person other than an owner thereof or to impede the recovery by an owner thereof, and when the value of the property exceeds fifty thousand dollars.” A person charged with a crime is innocent unless proven guilty by proof beyond a reasonable doubt in a court of law.

Assuming that New York state law is being used to prosecute a theft of ancient coins from Italy, such a prosecution would be new.

At a conference in 2005 and then in a paper in 2007, I argued that state law could be employed in the same way as the federal National Stolen Property Act (NSPA) to tackle international cultural property crime. In an excerpt from the 2007 paper, entitled International Antiquities Trafficking: Theft By Another Name, I wrote:

District and county attorneys can rely on receiving stolen property statutes to target culpable receivers and sellers of antiquities .... Every state has enacted a receiving stolen property statute in some form. These laws prohibit a person from receiving property of another when the person knew the property was stolen. Many of these same statutes also criminalize situations where the person should know, had reason to know, had reason to believe, or simply believed that the property was stolen or probably stolen .... While state receiving stolen property laws are fundamentally similar to the federal NSPA, many provide distinct advantages to prosecutors.

First, several state statutes establish lower mental states. The NSPA requires proof that a person knew the received property was stolen, but several states only require proof that the actor should know, had reason to know, had reason to believe, or simply believed that the property was stolen or probably had been stolen. Thirty six states and the District of Columbia have enacted laws with a lesser mens rea.

Second, almost one quarter of the states possess some form of dealer provision, making it easier to prosecute antiquities traders. Where a dealer takes possession of an item and either (a) does not reasonably gather information about whether the item was lawfully sold or delivered to the dealer, (b) acquires the item for payment far below reasonable value, or (c) purchases or sells the item outside of the regular course of business, these statutes generally declare that the dealer is presumed to have known that the item was stolen. The New York Penal Law serves as an illustration of scenario “a”: 'A … person in the business of buying, selling or otherwise dealing in property who possesses stolen property is presumed to know that such property was stolen if he obtained it without having ascertained by reasonable inquiry that the person from whom he obtained it had a legal right to possess it (§ 165.55(2)).'

Third, state receiving stolen property statutes provide criminal penalties for defendants who possess property of most any value as compared with the NSPA’s $5,000 threshold.

The legal advantages of lower mental states, dealer presumptions, and decreased value thresholds make prosecuting antiquities trafficking under state law an appealing option, particularly when targeting receivers or sellers.

David Gill, Paul Barford, and the Chasing Aphrodite authors are acknowledged for bringing attention to this developing story.

Monday, January 9, 2012

Apollo 14 Commander Alan Shepard left artifacts on
the lunar surface, including two golf balls
that he drove "miles and miles and miles."
The lunar lander, Antares, appears in the left shadow.
Astronaut Ed Mitchell's shadow is cast (center)
as he takes Shepard's photo. Courtesy NASA.

Materials relating to space heritage consist of natural astromaterials, man-made objects used in space-related activity, and tangible evidence of human activity such as Neil Armstrong’s first lunar boot print. They deserve to be preserved.

While some have begun this conversation already in the context of the Moon Treaty of 1979, the Outer Space Treaty of 1967, and other legal regimes, the time is ripe to more fully discuss space heritage in earnest as new groups venture beyond the earth's atmosphere. USA Todayreports that China has just announced an ambitious plan to build a space station and to send astronauts to the Moon. Meanwhile, Virgin Galactic hopes to shuttle space tourists soon. It is therefore best to get ahead of the issue of heritage protection now rather than to hurriedly catch up at a later date.

Already NASA’s Office of Inspector General (OIG) released an audit report critical of the American space agency for not keeping current track of moon rocks, stardust, meteorites, and other astromaterials in the space agency's possession. The December 8, 2011 report makes the following conclusion:

“For over 40 years, NASA has loaned astromaterial samples to researchers and shared lunar and meteorite exhibits with educators and the public. However, the materials remain the property of the U.S. Government and may only be borrowed for approved research, educational pursuits, and public display. Additionally, while loan periods may range from days to years, these transfers are not intended to be permanent, and NASA retains the right to recall its samples and exhibits at any time. Because NASA does not have adequate controls in place, the Agency cannot be sure of the location and security of all of its loaned astromaterials and therefore is at risk of losing these unique and limited resources.”

Astronaut James Lovell.
Courtesy NASA.

It may be no surprise that NASA, perhaps motivated by the release of the OIG report, challenged the authority of an auction house to sell an Apollo program mission artifact. Days ago the Associated Press reported that “NASA is questioning whether Apollo 13 commander James Lovell has the right to sell a 70-page checklist from the flight that includes his handwritten calculations that were crucial in guiding the damaged spacecraft back to Earth. The document was sold by Heritage Auctions in November for more than $388,000....” The Associated Press added that “[a]fter the sale, NASA contacted Heritage to ask whether Lovell had title to the checklist. Greg Rohan, president of Dallas-based Heritage, said Thursday the sale has been suspended pending the outcome of the inquiry,” noting that there is precedent for astronauts to have title to mission materials.

Lawmakers and stakeholders would be prudent to discuss and develop clearer policies now that specifically govern space heritage.

Sunday, January 8, 2012

The Archaeological Institute of America on Friday awarded David Gill the Outstanding Public Service Award. His blog, Looting Matters, is an important read for anyone interested in cultural property ethics. Congratulations to you, David!

Friday, January 6, 2012

UNESCO has produced the short documentary below titled "Fighting Illicit Traffic of Cultural Heritage in South Eastern Europe." The report is especially relevant as the Cultural Property Advisory Committee (CPAC) this month considers requests by Bulgaria and Cyprus for cultural property protections under the Cultural Property Implementation Act (CPIA).

Thursday, January 5, 2012

The United States District Court for the Northern District of Florida has ordered the forfeiture of the painting, the Cristo Portacroce Trascinato Da Un Manigoldo. The court issued the default judgment once the previous possessors, Italy and its Brera Art Gallery, failed to make a claim for the return of the artwork.

The court's ruling was brief: "Upon Application of the Plaintiff(s) in the above styled cause and having examined the records and there appearing to be no responsive pleadings filed by the defendant(s), default is hereby entered against the Italian Republic, Ministry of Culture, and the Pinacoteca di Brera, on January 3, 2012."

The painting will likely be handed over to the heirs of Federico Gentili di Giuseppe, who filed a claim on December 14, 2011 arguing that they were the lawful owners. Prosecutors submitted information to the court that the painting was taken from the family by the Nazis during World War II. Click here for details.

Federal officials seized the Cristo Portacroce in November 2011, which the Mary Brogan Museum of Art and Science in Florida had on loan. See here for background.

Wednesday, January 4, 2012

Kourion, Cyprus. Mosaic from the house of Eustolios.
Source: Lapost. CC.

Comments have been submitted to the Cultural Property Advisory Committee (CPAC) regarding an extension of the cultural property Memoranda of Understanding (MoU) between Cyprus and the United States as well as Peru and the United States. The original MoUs authorized by the Cultural Property Implementation Act lasted for five years and placed import restrictions on designated archaeological and ethnological material. There were a total of 336 comments electronically submitted to the State Department regarding Cyprus’ request and 23 comments regarding Peru’s request.

A sampling of the comments submitted in support of Peru’s request were published in a prior post. Comments regarding the Cypriot request appear below.

Writing in support of Cyprus’ request for an extension of the MoU, Professor A. Bernard Knapp, Honorary Research Fellow at the Cyprus American Archaeological Research Institute remarked:

“As a retired archaeologist . . . I am keenly aware of the importance of this MoU, which prevents archaeological objects from categories described in the Designated List from enter the US unless they have an export permit issued by the Government of the Republic Cyprus, or documentation that they left Cyprus prior to the effective date of the restriction. In my view, this MoU represents one of the most important documents protecting a country’s indigenous cultural heritage that the US has ever approved; it is an extremely significant tool in Cyprus’s efforts to prevent and combat the looting of its cultural heritage and the illicit trafficking of Cypriot antiquities to the United States, which has one of largest art markets for such antiquities in the world.”

“Signed originally in 2002, amended in 2006 to include Byzantine Period Ecclesiastical and Ritual Ethnological Materials, and renewed in 2007 to include Cypriot coins (end of 6th century BC to AD 235, the Government of the Republic of Cyprus now requests another amendment, to include Ecclesiastical and Ritual Ethnological Materials representing the post-Byzantine period dating up to AD 1850. They do so in order to assure a coherent legal framework in line with the Cyprus’s Antiquities Law. This request is based on numerous recent cases involving the illicit trafficking of ecclesiastical and ritual ethnological material that dates later than AD 1500.”

Elizabeth Bartman, President of the Archaeological Institute of America, also wrote in support of the MoU renewal:

“The archaeological evidence from such Bronze Age towns as Kourion [in Cyprus] attest to an active trade and a high level of technical production of ceramics, metal, and stone sculpture. Unfortunately, many of these distinctive artifacts are much prized by collectors today; the ravaging of the island after the Turkish invasion in 1974 has long been recognized, but looting continues today with loose controls in the northern zone permitting the export of both archaeological and ecclesiastical material. Because of their random findspots and portability, coins are especially vulnerable to looting and so deserve protection under the Memorandum.”

The comments opposing Cyprus’ request came from the ancient coin collecting community, which does not favor the inclusion of coins in any import protections. For example, Philip Griest wrote:

“Coins and modern paper money have always been fluid currency. The exchange of money for goods and services internally and internationally has exsited since ancient times. To now require that a specific coin be repatriated because of it's artistic worth seems illogical if not illegal. The money belongs to the person that earned it and then, when spent, to the person who traded for it; no matter goods, services or an exchange of currency. To return such items to the nation that minted the coin is to restrict trade and create an illegal market for the coin. What else can be done to these thousands or hundred (sic) of thousands of coins and artifacts. They can't all end up in museums. Has comman (sic) sense ceased to exist in our nation.”

And Glenn Saylor, Jr. wrote:

“I am against import restrictions of Cypriot coins into the United States. There are a large number of collectors of these coins in the United States. We carefully conserve these coins for future generations, and share our knowledge about these coins with not only our fellow collectors, but also the general public. Most of these coins are common, so Cyprus should have little diificulty obtaining needed examples for their museums. Since these coins are so common, it is hard to establish their providence. The net effect is that these common coins will not be allowed import into the United States. All rebutable (sic) coin dealers and collectors are against the looting of archaeological sites. However, I believe other methods can be used to address this issue. For instance in Great Britian (sic), the Government has the first right to buy new coin finds at market price. If this policy was implimented (sic) in Cyprus, their Government would have the first opportunity to purchase any rare coins that were found.”

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